TRANSPARENCY IN ALGORITHMIC GOVERNANCE: IMPLEMENTING THE COE FRAMEWORK CONVENTION THROUGH ADMINISTRATIVE LAW

Laura Muzi

Abstract

This article examines how transparency can function as a foundational safeguard in algorithmic governance within the European legal space. The Council of Europe’s Framework Convention provides a broad, rights-oriented vision of transparency grounded in intelligibility, oversight and participation. In contrast, the EU AI Act adopts a predominantly technical, market-driven approach, offering complementary but more limited transparency obligations. The paper argues that national administrative law plays a crucial role in operationalising these frameworks by articulating transparency as a multi-layered principle – combining access to information, reason-giving, participation and review – to address the structural opacity of AI systems. Through this administrative infrastructure, algorithmic decision-making can be reconciled with democratic accountability and the rule of law.

TABLE OF CONTENTS

  1. Transparency as the missing link in AI Governance

  2. Transparency and the CoE Framework Convention

  3. Beyond the AI Act: Transparency as an administrative principle

  4. Transparency as a Democratic Safeguard

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